Mandatory Disclosures as per Clause 38 of IFSCA Circular - Regulatory Framework for Global Access in the IFSC dated August 12, 2025

Last updated - August 1, 2026

INDmoney Global (IFSC) Private Limited (“INDmoney Global”/ “Company”) is mandated to disclose to investors risk factors relating to investments in Global Market, roles and responsibilities of entities involved in providing global access, Details of custody arrangements, Account structure, Trading related information including methodology used for calculating profit and loss of investors and other details as laid down under Clauses 38 and related provisions of IFSCA circular — Regulatory Framework for Global Access in the IFSC and the IFSCA (Capital Market Intermediaries) Regulations, 2025.

  1. Risk Factors Relating to Investment in Global Markets
    1. Market & Interest Rate Risk

      Investments are executed in markets outside the IFSC, which operate under different laws, trading hours, holiday calendars, disclosure norms, and investor-protection standards. Prices may fluctuate due to local or global market conditions.

    2. Currency Risk

      Foreign investments are subject to exchange-rate fluctuations. Adverse currency movements may reduce or negate investment gains when converted to the investor’s base currency.

    3. Custody Risk

      Securities or funds may be held with foreign brokers, custodians, or other intermediaries. Their insolvency, operational failure, or negligence could lead to partial or total loss of investments.

    4. Liquidity and Settlement Risk

      Settlement cycles and market liquidity may differ across jurisdictions. Variations in market practices or operational processes could cause delays in execution or settlement of trades.

    5. Technology, Time-Zone Risk & Cyber Attack Risk

      Orders placed through electronic systems across different time zones are exposed to latency, outages, or price gaps due to time-zone differences and system dependencies. In the event of a cyber-attack, there is a risk that the confidentiality, integrity, or availability of data, including personal information such as name, email address, contact details, and other sensitive information, may be compromised.

    6. Product and Suitability Risk

      Products available in foreign markets may be complex and involve higher risk than domestic instruments. Investors must ensure that such products suit their financial condition, objectives, and risk tolerance.

    7. Regulatory and Legal Risk

      Foreign investments are governed by the laws and regulations of the relevant jurisdiction. Investor-protection standards, disclosure requirements, dispute-resolution mechanisms, and supervisory frameworks may vary from those in India or the IFSC. Investors should remain informed of applicable regulatory changes.

    8. Taxation Risk

      Investments may attract taxes, withholding, or reporting obligations in both India and the foreign jurisdiction. Tax treatment is subject to change without notice. Investors are responsible for ensuring compliance with all applicable tax laws (including concerned foreign jurisdiction) and maintaining adequate records/ documentation.

    9. Remittance and Regulatory Compliance Risk

      All fund transfers must comply with the applicable laws of India, the IFSC, and the foreign jurisdiction, including the Reserve Bank of India’s Liberalised Remittance Scheme (LRS). Any breach of such rules may attract regulatory or penal action.

    10. Social and Political Risk

      Orders placed across international markets attract social and political risk, significantly affecting the profitability of the sector or the expected value of a given economic action. Investor shall remain updated with the changes in the political and economic movements in the concerned foreign jurisdiction.

  2. Roles and responsibilities of entities involved in providing global access

    Alpaca Securities LLC and DriveWealth LLC is a US based clearing broker registered with the U.S. Securities and Exchange Commission (SEC) and is a member of FINRA. Alpaca Securities LLC and DriveWealth LLC are members of multiple US stock exchanges.

    GTN Asia Financial Services (Pte.) Ltd is regulated by the Monetary Authority of Singapore (“MAS”) and holds a Capital Markets Services licence and it is a member of London Stock Exchange.

  3. Details of custody arrangements

    Foreign Securities shall be held in custody in such form (including street name, nominee holding, DTC book-entry form, CSD book-entry form, or fractional form) as is customary or required in the relevant foreign market. For details, please refer to the Company’s Consolidated Account terms at https://www.indmoney.com/page/consolidated-account-terms

  4. Account structure

    Investors are required to register on the INDmoney Global platform and complete all KYC procedures mandated by the Regulatory Framework for Global Access in the IFSC and the IFSCA (Capital Market Intermediaries) Regulations, 2025 and other regulatory guidelines. Upon successful AML-KYC verification, INDmoney Global will open a trading account for the investor.

    Unlike the fully disclosed account, under the Consolidated Account structure, INDmoney Global does not open a separate clearing or brokerage account in the investor’s name with any overseas broker-dealer. Instead, an Investor Account (sub-ledger / Tracking Account) is maintained on the Company’s own books in the investor’s name, recording the investor’s Beneficial Interest in Foreign Securities and Funds held within the Consolidated Account.

    Under fully disclosed, INDmoney Global will open a trading account for the investor. Foreign stocks trade execution/ settlement necessitates use of a U.S. clearing broker, INDmoney Global may facilitate the opening of a clearing account with Foreign broker; the opening and continued operation of the clearing account shall be conditional upon the investor’s fulfillment of specific Foreign broker’s KYC, onboarding and any other applicable requirements.

  5. Trading related information including methodology used for calculating profit and loss of investors

    Under the Consolidated Account structure, investor orders for Foreign stocks placed on the INDmoney Global platform are validated and routed by INDmoney Global to the applicable Foreign broker for execution. Orders may be aggregated with orders of other investors for operational efficiency, and executions are allocated fairly. Trades are cleared and settled through the Foreign Broker acting on behalf of the Company.

    Under Fully disclosed model, the trading activities related to Foreign stocks on INDmoney Global platform and fulfillment and clearing of the trades are done by the Foreign Brokers directly for the investor.

    All computation of holdings, average prices, quantity, and profit and loss are done basis the FIFO method as a general practice and shown to the investor on the INDmoney Global platform.

    All reports of transactions, holdings and tax p&l are available on INDmoney Global platform for the investor to download as per India tax reporting formats

    Illustration of FIFO methodology used while buying & selling of US shares

    FIFO stands for First-In, First-Out. It is a method used to track which shares are sold when you make a sale, especially when you’ve bought the same stock multiple times at different prices. Under FIFO, the oldest shares (first bought) are assumed to be sold first. This is the standard method used in India (as per Income Tax rules) and globally.

    Example: Let’s say you buy shares of Company XYZ multiple times:

    1. BUY - Jan 1 - 10 Shares - $100 per share
    2. BUY - Feb 1 - 10 Shares - $120 per share

    And then SELL 15 shares on 1 Mar at $150 per share. As per FIFO:

    1. First, 10 shares from Jan 1 ($100 each) are sold
    2. Then, 5 shares from Feb 1 ($120 each)

    Realized Gain:

    1. 10 × ($150 − $100) = $500
    2. 5 × ($150 − $120) = $150
    3. Total Realized Gain = $650

    Note - When shares are sold, the invested value is not reduced by the sale proceeds. Instead, the invested value is adjusted based on the original cost of the shares sold, which is calculated using the FIFO (First In, First Out) method.

  6. Applicable fee structure

    Investing in US stocks through INDmoney Global is highly affordable and competitive in the industry, with minimal charges:

    1. Opening a US stocks account via INDmoney Global is Free
    2. Zero AMC (Annual Maintenance Charges)

    Read more about INDmoney Global charges

    (*Subject to regulatory changes)

    No charge other than what is disclosed here will be collected from the investor.

  7. Applicable investor protection scheme or insurance coverage

    Depending on the jurisdiction of the Foreign Broker and the nature of the relevant investor-protection regime (including, in the United States, coverage under the Securities Investor Protection Corporation (“SIPC”)), the Customer’s recoveries in the insolvency of the Company or Foreign Broker may be based on a pro-rata or aggregated claim at the Company level, and may be subject to limits, exclusions and procedural requirements that would not apply in a fully-disclosed account. Any such coverage, where available, is provided to the Company (or its nominee) as the account holder of record, and is generally not available directly to the Customer.

  8. Applicable tax structure

    For Indian residents:

    1. Short‑Term Capital Gains (STCG): If US stocks are sold within 24 months, gains are taxed as per your income‑tax slab.
    2. Long‑Term Capital Gains (LTCG): If sold after 24 months, gains are taxed at 12.5% without indexation.

    Read all about Tax Implications on US Stocks

    1. Estate Tax: The US estate tax is a federal tax levied on the value of a person’s assets at the time of their death, before those assets are transferred to their heirs.

    Read all about Estate Tax implication on US Stocks

  9. Timely communication of corporate announcements

    Corporate announcements such as mergers, dividends and bonus/splits are communicated to investors on a best effort basis on INDmoney Global platform.

    Dividends, Bonus and other corporate actions are performed by the clearing foreign broker and will reflect on INDmoney Global platform. Dividends paid out to investors are credited directly to the investors wallet post deduction of applicable withholding taxes.

    Dividends and distributions declared in respect of Foreign Securities in which the Customer holds a Beneficial Interest shall be credited to the Customer Account after deduction of (i) any withholding tax at source at the rates applicable in the country of the issuer or the relevant market, with treaty relief where available subject to prescribed documentation (for example, in the case of U.S. securities, generally 30%, reduced to 25% under the India-U.S. Double Taxation Avoidance Agreement upon submission of a valid IRS Form W-8BEN by the Customer, subject to Applicable Law); and (ii) any fees, custodian charges, ADR pass-through fees and similar charges.

  10. Entry fee, exit fee, fund withdrawal charges, account transfer charges, account closure charges or any other charges shall be disclosed at the time of onboarding investor and an undertaking that no other charge other than what is disclosed will be collected from the investor.

    There is no Entry fee, exit fee, fund withdrawal charges, account transfer charges or account closure charges.

    Read more about INDmoney Global charges

  11. Regulatory requirements with respect to trading in such foreign Jurisdiction

    The Resident Indian investor’s participation in global markets through the authorised Global Access Provider (GAP) is subject to compliance with all applicable laws and regulations, including but not limited to the Foreign Exchange Management Act, 1999 (FEMA) and the Liberalised Remittance Scheme (LRS) of the Reserve Bank of India (RBI).

    Remittance towards investing in US Stocks via the Liberalized Remittance Scheme (LRS) is regulated by the Reserve Bank of India (RBI). As a resident Indian, you are allowed to remit up to $250,000 a year. Read more about Liberalised Remittance Scheme. As per applicable RBI LRS requirements, funds not utilized for their intended purpose should be repatriated to your registered bank account within 180 days in accordance with Regulation 7 of Foreign Exchange Management (Realisation, repatriation and surrender of foreign exchange) Regulations, 2015.

    Investor understands the trade Access Restriction with regards to:

    1. a. Crypto-assets and instruments having underlying assets as crypto or any other instruments
    2. b. Index derivatives, single stock derivatives, bond derivatives or USD-INR/INR-USD derivatives that are available on Recognised Stock Exchanges in the IFSC.

    Investors can reach out to INDmoney Global for any kind of complaints/ grievances as per the process laid down in the Policy on Complaint Handling and Grievance Redressal - Global Access . Investors are requested to acknowledge that all disputes related to Global Access will not have access to the Rights of investors or investor protection; Dispute resolution mechanism; and Investor grievance redressal mechanism of the recognised stock exchanges in the IFSC.

  12. By continuing, I confirm that I have read, understood, and accepted these risks and disclosures.